United States Region 10 EPA-10-ID-WQMP-II-79
Environmental Protection 1200 Sixth Avenue
Agency Seattle WA 98101
Water March 1980 £PA 910/9-79-061
Environmental
Assessment
Idaho Agriculture El-
Grazing Practices
Idaho Statewide
Water Quality Management Plan
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
\3SZ1
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
ftEPLY TO
ATTN Of
M/S 443
V 10 1980
To All Interested Government Agencies, Public Groups and Citizens:
Pursuant to Section 102(2)(c) of the National Environmental Policy Act
of 1969 and Section 208 of the Clean Water Act of 1977, I am forwarding
this Final Environmental Assessment for the Agriculture and Grazing
Practices element of the Idaho Statewide Water Quality Management Plan.
Earlier you received the Draft Environmental Assessment. This document
supplements the draft assessment and contains a suimiary of the draft
environmental assessment, an errata section, letters of comment on
the draft environmental assessment, and responses to those coirments.
This assessment forms a technical appendix to the Water Qualtiy Manage-
ment Plan. The Agricultural element of the Plan was certified by the
Governor of the State of Idaho and was approved by EPA on September 26,
1979. The total Plan is expected to be approved by EPA by April 30, 1980.
If you have any questions or comments, please contact:
Additional copies of this document may be requested at the above address.
Sincerely,
Craig Partridge
Environmental Evaluation Branch
EPA Region 10
1200 Sixth Avenue, M/S 443
Seattle, Washington 98101
Donald V. Dubois
Regional Administrator
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FINAL ENVIRONMENTAL ASSESSMENT
IDAHO AGRICULTURE AND GRAZING PRACTICES
Idaho Statewide Water Quality Management Plan
Prepared By:
U. S. Environmental Protection Agency
Region 10
Seattle, Washington 93101
With Technical Assistance From:
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, California 95816
H. Esmaili and Associates, Inc.
2713 Telegraph Avenue, Suite 200
Berkeley, California 94705
Responsible Official:
Donald P. Dubois
Regional Administrator
MAR 10 ?SS0
Date
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TABLE OF CONTENTS
Page
Chapter 1 - INTRODUCTION 1
History and Purpose of Water Quality Manage-
ment Plan 1
Purpose and Content of the Final Environmental
Assessment 4
Distribution of Environmental Assessment 5
Chapter 2 - SUMMARY OF ENVIRONMENTAL ASSESSMENT REPORT 7
Section I - Irrigated and Nonirrigated
Agricultural Lands 7
Section II- Livestock Grazing 20
Chapter 3 - ERRATA 35
Chapter 4 - COMMENTS ON THE DRAFT EA AND EPA
RESPONSES 37
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Chapter 1
INTRODUCTION
History and Purpose of
Water Quality Management Plan
The Clean Water Act (PL 92-500) and its amendments
(PL 95-217) set forth the objective "to restore and maintain
the chemical, physical and biological integrity of the Nation's
waters." Under Section 208 of the act, each state is authorized
to develop a statewide water quality management plan to 1)
identify nonpoint source water quality problems, 2) develop
strategies for their solution and methods to implement such
solutions, and 3) develop a process for evaluating plan
effectiveness in meeting goals of the Clean Water Act.
Using Section 208 grant funds, the State of Idaho, through
the State Department of Health and Welfare (IDHW) m association
with the State Soil Conservation Commission and others, prepared
the statewide Water Quality Management Plan (1979) • An element
of this plan is the Agricultural Pollution Abatement Plan
which sets forth strategies for reducing the discharge to
state waters of nonpoint source pollutants from Idaho's agri-
cultural lands. The plan addresses irrigated and dryland
agriculture and livestock grazing on rangelands. The Environ-
mental Assessment (EA) report treats these lands in two sections:
Section I - Irrigated and Nonirriqated Lands, and Section II -
Livestock Grazing.
Objective and Approach of the Plan
The overall objective of the plan is to achieve compliance
with the federal pollutant elimination clause of PL 92-500,
as amended, through the control of agricultural nonpoint
sources of pollution. The proposed pollution control strategy
combines the identification of particular geographic areas
or stream segments which are believed to have significant
agriculturally-related water quality problems with a catalog
of appropriate Best Management Practices (BMPs)1 which, when
1m... a practice, or combination of practices, that is deter-
mined by a state ... to be the most effective, practicable ...
means of preventing or reducing the amounts of pollution
generated by nonpoint sources to a level compatible with
water quality goals."
1
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Figure 1-1
STREAM SEGMENTS RATED AS
MODERATELY OR SEVERELY
AFFECTED BY AGRICULTURE
r 1
I '
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applied on individual farms, should serve to effectively
reduce the discharge of sediments, nutrients, salts and other
pollutants into water bodies. To stimulate the application
of BMPs, the plan recommends that a voluntary program be
adopted, primarily utilizing on-going programs. A back-
up regulatory program which could be enacted if the voluntary
program fails to achieve satisfactory improvements in water
quality is also outlined.
Development of the Plan
The draft plan represents the culmination of two years
of effort by the staff of the Idaho Soil Conservation Commis-
sion, the local Soil Conservation Districts, several special
consultants and numerous cooperating agencies and individuals.
During the formulation of the plan over 200 public meetings
involving 4,000 participants were held throughout the state
to solicit input from the agricultural community and the
general public. In addition, the 208 Policy Advisory Committee
and Agriculture Subcommittee served as a forum for policy
debate throughout all steps of the planning process. The
resulting document, therefore, reflects the concerns of a
broad cross section of the population of Idaho, in addition
to adhering to the legislative requirements of the Clean Water
Act.
Scooe of Water Quality Problems
As a first step in the formulation of an action plan,
an assessment of the water quality impact resulting from
agricultural activities in Idaho was undertaken. Each Soil
Conservation District, through knowledge of lands within
their jurisdiction, prepared maps identifying areas with
slight, moderate or severe erosion problems. These data,
combined with information from the water quality monitoring
network, served as the basis for problem identification.
A prioritized list of adversely affected stream segments
was developed from a state level analysis of the data base.
The distribution of adversely affected segments is shown
in Figure 1-1.
The plan recommends a staged approach toward remedial
action rather than an immediate blanket attack on agricultural
lands draining into the affected stream segments. Streams
and their terrestrial environs rated as having severe nonpoint
source problems will be assigned first priority for action,
followed by those areas considered to be moderately affected.
The large number of streams rated as being only slightly
impacted by agricultural activities will be dealt with last,
3
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if at all, subject to funding constraints and the observed
degree of success of control measures applied to the higher
priority areas.
Technical Solutions
The tecnnical basis for agricultural nonpoint source
pollution control is the application of BMPs on the farm.
A comprehensive combination of BMPs which when applied to
a specific land use should result in significantly reduced
pollutant discharge is termed a Resource Management System
(RMS). The source of BMPs is the Soil Conservation Service's
Technical Guide which defines standards and specifications
for each individual practice.
Each Soil Conservation District in Idaho compiled a
list of BMPs which were deemed to be suitable for correcting
on-farm erosion problems in their respective service areas.
Purpose and Content of the
Final Environmental Assessment (EA)
The National Environmental Protection Act (NEPA) as
implemented through the Council on Environmental Quality
(CEQ) guidelines and the U. S. Environmental Protection Agency
(EPA) regulations requires the EPA to prepare an EA on all
actions that could adversely affect the environment, either
natural or socio-economic.
A Draft EA of the agriculture and grazing practices
elements of the Idaho statewide water quality management
plan was prepared and distributed by EPA on August 2, 1979.
Comments on the Draft EA v/ere to be received by the EPA by
October 9, 1979.
Several comments on the Draft EA were received, and
are responded to in this report. Based on recent changes in
CEQ guidelines, the Draft EA can be revised in its entirety
to reflect the correction of errors and chanqes in content
resulting from agency and public comment, or a supplementary
document can be prepared that includes only the comments
and EPA responses to the comments. Because it is believed
that: comments on the Draft EA did not raise substantive new
issues about or create significant changes m the Idaho state-
wide water quality management plan, this Final EA is prepared
as a supplement to the Draft EA.
4
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This introduction is followed by a summary of the EA
report. It is organized m two sections: Section I -
Irrigated and Monirrigated Lands, and Section II - Livestock
Grazing. This summary is followed by Chapter 3 - ERRATA
whicn identifies and changes reported errors in the Draft
EA. Chapter 4 gives the individual letter comments on the
Draft EA followed by the EPA response to each comment. All
letters of comment received by the EPA are included.
Distribution of the Environmental Assessment
EPA is distributing this EA to the following parties:
FEDERAL AGENCIES
U. S. Department of Agriculture
Soil Conservation Service
Agricultural Stabilization and Conservation Service
Area Conservationist
State Conservationist
Forest Service
U. S. Department of Commerce
National Marine Fisheries Service
U. S. Department of Defense
Corps of Engineers
U. S. Department of Health, Education, and Welfare
U. S. Department of Housing and Urban Development
U. S. Department of Interior
Bureau of Land Management
U. S. Fish and Wildlife Service
U. S. Department of Transportation
Federal Energy Office
Advisory Council on Historic Preservation
STATE AGENCIES
Office of the Governor
Department of Health and Welfare
Department of Lands
Soil Conservation Commission
Division of State Planning
Department of Fish and Game
Department of Parks and Recreation
Department of Water Resources
University of Idaho
Cooperative Extension Service
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LOCAL AGENCIES
Lemhi County, Office of County Commissioners
ORGANIZATIONS
Idaho Conservation League
Idaho Environmental Council
Idaho Wildlife Federation
This EA will also be widelv distributed to interested
oarties by the IDHW.
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Chapter 2
SUMMARY OF ENVIRONMENTAL ASSESSMENT REPORT
Section I - Irrigated and Nonirrigatsd
Agricultural Lands
The Agriculture Industry in Idaho
Approximately 13 percent or 6.9 million acres of Idaho's
land area are devoted to crop production, including improved
pasture. Irrigated lands cover about 3.8 million acres and
the balance of the cropped acreage is dry farmed. Sixty-
five percent of the state or approximately 21.3 million acres
are grazed, making livestock grazing the most extensive land
use activity in the state.
The Upper Snake River and Southwest Idaho Basins are
the major crop-producing areas of the state. Grains, potatoes,
sugar beets, hay, vegetables, and pasture are the predominant
crops raised in Idaho. About 14 percent of the Palouse River
Basin lies within Idaho, and this dry farmed area produces
large quantities of grain. Grazing land is distributed
throughout the state.
Estimates of the average volume of water diverted for
irrigating an acre of land vary from 4.3 to 6.5 acre-feet
per acre per year. In 1970, agriculture accounted for
96 percent of the consumptive use in the state. Approxi-
mately 86 percent of the agricultural water supply is obtained
from surface streams and the remainder is pumped from ground-
water aquifers. In 1975, about 66 percent of the irrigated
crop acreage was under surface irrigation and the balance
was sprinkler irrigated.
The 'use of nitrogenous fertilizers increased from 102,000
tons in 1972 to 139,000 tons in 1975. Phosphate fertilizer
use varied from 59,600 tons to 61,100 tons during the same
calendar years. In addition, 12,800 tons of potassium
compounds and 18,000 tons of micronutrient were used in the
state in 1975.
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The Idaho state water plan envisions the development
of 987,000 acres of new irrigated land over the next 40 years.
Most of this acreage will be developed in the Upper Snake
and Southwest Idaho Basins. In addition, 379,000 of the
estimated 650,000 acres of land currently receiving inadequate
quantities of water will receive supplemental water supplies
under the plan. Increased utilization of groundwater supplies
is expected to provide half of the anticipated additional
demands. Most of the new acreage is expected to be sprinkler
irrigated.
Since the majority of potentially irrigable lands in
Idaho are currently under federal and state ownership, the
Desert Land Entry and Carey Acts will be important vehicles
for transferring suitable tracts into private control.
Currently, approximately 1,400 applications are pending under
the Desert Land Entry Act which, if approved, would open
700,000 acres of native rangeland to irrigation development.
In addition, 140 applications involving about 662,000 acres
have been filed with the Idaho Department of Water Resources
since 1973, when permit procedures under the Carey Act were
reopened.
Agriculture ranks as the number one industry and
employer in Idaho. In 1977 total sales of agricultural
commodities brought the state 1.17 billion dollars. Approxi-
mately 44,000 persons are employed in agriculture on a year-
round basis. This number increases to 55,000 persons during
the growing season. By 19 88 agricultural employment is
estimated to decrease to 36,000 or 7.7 percent of the work
force, and by the year 2000 it will further decline to 29,000
or 4.6 percent of the work force. These projections are
based on the assumption that the trend toward the develop-
ment of larger and less labor-intensive farms will continue
into the future.
Agricultural Monpoint Source Pollution
Nonpoint source pollutant emissions from agricultural
and grazing lands fall into the following five general cate-
gories :
o Sediment
o Salinity
o Nutrients
o Pesticides
o Pathogens
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Discharge of these pollutants can adversely impact
receiving surface and groundwater resources. Erosion and
sediment transport are the major agricultural nonpoint
source pollution problems in Idaho. It is estimated that
more than 7 million tons, or approximately 4,000 acre-feet
of sediment annually reach the surface waterways from irri-
gated and dry farmed areas in Idaho. The bulk of the sediment
load is derived from dry farmed lands and is carried in snow-
melt or rainfall runoff. Highly erodible soils are found
throughout the northern panhandle area, the upper Snake River
Basin, and in the Bear River Basin. Gross erosion in the
state is estimated to be almost 26 million tons of which
about 60 percent results from both irrigated and dryland
farming in the Upper Snake River Basin.
Results of special investigations of irrigated and non-
irrigated cropland in selected basins in Idaho show that
other pollutants such as salinity, nutrients, pesticides,
and pathogens are also discharged to surface or groundwater
bodies in agricultural areas of the state. Three such case
studies are discussed in detail in Chapter 2 of the assess-
ment report on irrigated and nonirrigated agriculture.
In general, most surface streams in Idaho are adversely
affected by the discharge of sediment and nutrient-laden
agricultural return flows. However, the relative contribution
of agriculture to water quality degradation has not been
fully investigated. In the Panhandle and Salmon Basins only
minor agricultural pollutant loadings are discharged to surface
streams. In the Clearwater Basin, which contains the prairie
areas, significant sediment loads are discharged into surface
streams. Southwest Idaho and Bear River Basins contribute
about 8 and 12 percent of the statewide sediment load and
contain streams that are moderately or severely impacted
by these discharges. As indicated previously, the Upper
Snake River Basin contributes almost 50 percent of the sediment
load within the state. Most of this load is derived from
dry farmed areas. In addition to sediment, significant quan-
tities of salts, nutrients, and pesticides enter the waterways
from extensive agricultural tracts along the Snake River.
A wide range of water quality problems have been identified
in the Snake River including high turbidity levels, nutrient
enrichment and bacterial, pesticides and aesthetic impairment.
Comprehensive information on groundwater resources in
Idaho has not been developed. Currently about 3.1 million
acre-feet of water are withdrawn annually for irrigation
use. In addition, most municipal and industrial requirements
9
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are met by groundwater supplies. A readily apparent impact
of irrigated agriculture on groundwater has been documented
in the western half of Boise Valley where water table elevations
have risen by 100 feet since the implementation of the Boise
project. Conversely, m the Snake Plain aquifer, the Raft
River Valley, and other critical groundwater areas, water
levels have dropped due to irrigation pumping. Both of the
above conditions could result in degradation of water quality
under specific conditions. Specific cause and effect analyses
for areas of degraded groundwaer quality are currently being
carried out by state agencies in Idaho.
Legal and Institutional Setting
Various governmental agencies and legislation at federal,
state and local levels form the institutional and legal setting
for implementation of nonpoint source pollution control programs
(Figure 2-1). The Clean Water Act of 1972 and its amendments
created a federal mandate to "restore and maintain the chemical,
physical and biological integrity of the Nation's waters".
Section 20 8 of the act authorizes the development of areawide
waste treatment management plans. These plans must contain
a detailed identification of water quality problems, a strategy
for their solution, a program for the implementation of such
solutions, and a process for evaluating their effectiveness
in accomplishing the stated clean water objectives. The
plan is required to include a regulatory control program
to assure the achievement of effective nonpoint source
pollution control. While nonregulatory or voluntary programs
are also acceptable, such plans must contain provisions for
a backup regulatory program to be implemented m the event
that satisfactory compliance is not attained through voluntary
action.
With respect to agriculture, Section 208 stipulates
that areawide planning must include "a process to (l) identify,
if appropriate, agriculturally related nonpoint source of
pollution, including return flows from irrigated agriculture,
runoff from manure disposal areas, and from land used for
livestock and crop production, and (ii) set forth procedures
and methods (including land use requirements) to control,
to the extent feasible, such sources". Section 208 interfaces
with several other sections of the Clean Water Act affecting
other aspects of water pollution control.
EPA has been authorized to administer the Clean Water
Act. However, the EPA administrator can delegate specific
responsibilities to state or regional agencies. In Idaho
the governor has named the Department of Health and Welfare-
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FIGURE 2-1
INSTITUTIONAL MANAGEMENT OF
THE PROPOSED AGRICULTURAL
POLLUTION ABATEMENT PLAN
VOLUNTARY PROGRAM
REGULATORY PROGRAM
11
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Division of Environment as the statewide authoncy for 208
planning. This agency subsequently delegated responsibility
for preparation of the Agricultural Element of the 208 plan
to the Idaho Soil Conservation Commission.
In addition to the EPA, the U. S. Departments of Agri-
culture (USDA) and Interior also have major responsibilities
in the area of agricultural resource conservation. In fact,
the USDA is the major federal agency involved in agriculture
and administers a number of resource conservation programs
through its following subordinate agencies: Soil Conservation
Service, Agricultural Stabilization and Conservation Service,
and Farmers Home Administration. The Department of Interior
carries out major functions for managing the nation's land
and water resources through the following agencies: Bureau
of Land Management, Bureau of Reclamation, Geological Survey,
and Fish and Wildlife Service.
State agencies, in addition to the IDHW, with responsibility
in the field of agricultural consist of the following: USDA,
Department of Water Resources, Department of Lands, and Depart-
ment of Fish and Game. In addition, the University of Idaho,
through its Agricultural Experiment Station and the Cooperative
Extension Service, is actively involved in agricultural research
and development in providing technical assistance to farmers,
ranchers and the general public.
Regional agencies involved in nonpoint source pollution
control planning in Idaho include three designated areawide
208 agencies and seven district health departments. The
designated 208 planning agencies have agreed to adopt the
statewide 208 plan for agriculture prepared by the Soil Con-
servation Commission.
Local agencies with broad regulatory authority include
the governing bodies of counties, cities, and towns. Non-
regulatory agencies at the local level include the Soil Con-
servation Districts and numerous special purpose districts.
The Soil Conservation Districts will play a major role m
carrying out the proposed voluntary program for nonpoint
source pollution control.
Many of the federal and state agencies cited in the
preceding paragraphs offer financial incentives and technical
assistance to farmers and ranchers under a variety of resource
conservation and/or crop acreage regulation programs. Most
of these programs such as the agricultural conservation,
resource conservation and development and rural clean water
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program provide funding of up to 100 percent of the cost
of implementing BMPs to achieve specific objectives in a
given area. Other programs such as Farmer's Home Loans,
Water Management Account or Small Reclamation Projects Act
provide low interest loans for farm improvements, water manage-
ment or soil reclamation facilities.
A review of the incentive programs shows that only a
small fraction of this effort is aimed specifically at the
control of nonpoint sources of pollution. Under some con-
ditions, these programs are also at cross purpose with water
pollution control objectives. For example, the set-aside
program under which the farmers are paid to reduce the
acreage planted to wheat and feed grains encourages the
practice of summer fallowing on wheat lands in the Palouse
Prairie, thereby aggravating the soil erosion problem. On
the other hand, set-aside acres are eligible for cost-sharing
under the agricultural conservation program if a nonharvestable
permanent crop such as pasture is planted. It appears that
modification of the set-asida program and better coordination
with the conservation and other programs may result in improved
resource conservation practices without increasing the overall
cost of these programs.
Idaho's Agricultural Pollution Abatement Plan
The pollution control strategy in the proposed plan
for the State of Idaho is based on the application of BMPs
on a farm-by-farm and ranch-by-ranch basis.
These BMPs will serve to effectively reduce the discharge
of sediments, nutrients, salts, bacteria and other pollutants
into water bodies. To stimulate the application of BMPs,
the plan provides for adoption of a voluntary program which
primarily utilizes the on-going agricultural resource con-
servation programs in the state. A backup regulatory program
is also outlined. The regulatory program could be enacted
if the voluntary program fails to achieve its intended objectives.
Plan Development. The draft plan represents the cul-
mination of 2 years of effort by the staff of Idaho Soil
Conservation Commission and the local Soil Conservation Districts.
Extensive public meetings wera held throughout the state
during the plan development process. Each soil conservation
district throughout the state prepared maps identifying the
degree of erosion hazard for lands under their jurisdiction.
These data, in combination with water quality monitoring in-
formation, were used as the basis for problem identification.
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The plan recommends a staged approach for solving agri-
cultural nonpoint source pollution problems. To this end
stream segments and the contributing agricultural and grazing
lands in areas with severe pollution problems are assigned
first priority for taking corrective action. Areas with
minimal pollution problems will have the lowest priority
on this ranking scale. The success or failure of the program
will not be solely judged by water quality enhancement goals,
but will include such factors as the availability of competent
technical personnel and adequacy of funds for providing
financial incentives.
Program Management. Idaho Division of Environment will
have overall responsibility for implementing the Agricultural
Nonpoint Source Pollution Control Plan as the designated
state 208 agency. The actual day-to-day management and
coordination of the plan at the state level will be carried
out by the Idaho Soil Conservation Commission. The primary
function of the Soil Conservation Commission will be to provide
assistance and guidance to the 51 local Soil Conservation
Districts and act as a liaison to other state and federal
agencies.
Local management of the program will be carried out
by the Soil Conservation District offices (Figure 2-2). Soil
Conservation Districts will provide technical and administrative
assistance to individual farmers and ranchers, carry out
follow-up monitoring, estimate financial requirements
for plan implementation, make recommendations for changes
m the BMP catalog, and receive and review complaints filed
under the backup regulatory program.
Resource Requirements for Plan Implementation. Sig-
nificant human ana financial resources will be needed for
implementing the proposed voluntary program. The plan envisions
the provision of significant grant funds for the design,
construction and use of BMPs on individual farms and on grazing
lands. The federal share of such costs could vary signi-
ficantly depending on the program under which the BMP is funded.
Under the revisions of the Clean Water Act up to 50 percent
of the cost of eligible nonpoint source pollution control
facilities may be supplied by the federal government. If
additional grant funds are deemed necessary, such funds would
have to be supplied by the State of Idaho or the entire project
would have to be funded under a different resource conservation
program.
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FIGURE 2-2
IMPLEMENTATION STRUCTURE OF
THE PROPOSED AGRICULTURAL
POLLUTION ABATEMENT PLAN
« INDICATES THAT PU8UC INVOLVEMENT WOULD BE REQUIRED
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The estimated total costs for implementing the three-
phase voluntary program are shown in Table 2-1 m 1979 dollars.
These data indicate an annual cost of 11 million dollars
for correcting erosion problems in severely affected areas.
If moderately affected areas are also brought into the program,
annual cost will increase to 36 million dollars. An additional
5 million dollars per year would be needed to treat the agri-
cultural areas of the state having slight erosion problems.
Although the major portion of the costs will arise from imple-
mentation of BMPs, a significant cost will also be incurred
in administering the program and for providing technical
assistance to farmers, ranchers and other affected entities.
These latter costs reflect the level of technical personnel
needed for achieving the plan's objectives.
Impacts of the Proposed Plan
The proposed plan, if implemented, will create several
environmental, social and economic impacts in the State of
Idaho. A brief summary of these impacts is presented in
this section.
Impacts on Water Quality and Quantity. The proposed
plan establishes an institutional and financial framework
for alleviating the pollution of surface streams in Idaho
where such pollution is caused by the discharge of sediment-
laden natural runoff or irrigation return flows from agri-
cultural lands. The degree of success in attaining this
objective is mainly dependent on the extent to which BMPs
are implemented and are effectively followed by farmers and
ranchers and on the level of funding of the three-phase
voluntary program.
The extent of known groundwater pollution in Idaho in
relation to irrigated agriculture, is relatively minor and
the proposed plan does not specifically address groundwater
pollution control measures. However, BMPs designed to alleviate
some surface water pollution problems would also have secondary
beneficial impacts on groundwater resources. Further, the
Idaho Department of Water Resources and the U. S. Geological
Survey are cooperatively investigating groundwater conditions
in various parts of the state. The results of these studies
will aid in delineating areas where implementation of specific
measures for groundwater pollution control may be required.
Some of the proposed BMPs for controlling erosion from
irrigated agricultural lands can result in significantly
increased irrigation efficiencies and consequently in lowered
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Table 2-1
ESTIMATED TOTAL COSTS TO,IMPLEMENT THE THREE-PHASE VOLUNTARY PROGRAM
Estimated Cost by Problem Severity, thousand dollars
Severe
Moderate & Severe
Slight, Moderate & Severe
Cost Item
Annual
20 Years
20 Years
Annual
20 Years
Annual
Technical and Support Staff:a
Cooperative Extension
Service
259
5 ,180
220
4 ,400
864
17 ,280
SCC Coordinator
30
600
30
600
30
600
SCD Supervisors
141
2 ,820
341
6,820
624
12,480
SCD Technicians
520
10 ,400
930
18,600
1,360
27,200
SCS Technicians
450
9,000
450
9,000
600
12,000
Research and Monitoring
200
4 ,000
200
4,000
400
8,000
Subtotal
1,600
32,000
2,171
43 ,420
3 ,878
77,560
DMP Application:*3
Irrigated Cropland
4 ,882
97,639
27,188
543,759
28,647
572,943
Dry Cropland
4 ,616
92,318
6 ,502
130,049
6,502
130,049
Pasture and Haylands
0
0
0
0
2 ,321
46 ,415
Subtotal
9,498
189,957
33,690
673,808
37 ,470
749,407
Total Cost
11,098
221,957
35,861
717,228
41,348
826,967
.includes all staff for education and technical assistance phases
3total cost of BMP installation
Source: Idaho Soil Conservation Commission, 1979
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oer acre irrigation water demands. However, the extent to
which farmers will select these BMPs as opposed to other
erosion control measures will probably depend on cost
effectiveness and cannot be predicted at this time.
Soil Productivity. Implementation of the proposed plan
will help the farmers and ranchers to better maintain the
long-term soil productivity by reducing the rate of erosion
and sediment transport from the state's agricultural and
rangeland soils.
Impacts on Fish and Wildlife. Improvements in the quality
of surface and groundwater bodies will enhance fish and wild-
life habitat in affected areas.
Economic Impacts. The proposed plan could significantly
affect the level of income of farmers and ranchers in the
affected areas if no financial assistance were provided for
implementation of BMPs. The competitive stance of affected
Idaho farmers and ranchers versus those in other parts of
the country could also be adversely affected in the absence
of significant financial aid.
Impact on Croo Production. The voluntary program may
create some limited impact on the types and quantities of
crops produced in Idaho. In some cases, land will be taken
out of production, whereas in cases where more efficient
irrigation systems are used for erosion control purposes,
new acreage could be brought under production. In addition,
a shift in the crop mix may occur as a direct result of imple-
mentation of the plan. The overall impact of the plan on
crop production in Idaho cannot be determined at this time.
This impact is not expected to be very significant.
Imnacts on Government Operations. The plan may require
the hiring of additional government personnel to handle the
anticipated work load. The local Soil Conservation districts
which are expected to carry most of the work load will be
significantly affected by the plan. The plan would also
increase the level of government jurisdiction over agriculture
especially if public funds are disbursed to farmers or ranchers
for implementing BMPs recommended by the Soil Conservation
District staff. In the absence of federal support the plan
will impose a significant financial burden on state and local
agencies which are responsible for implementing the program.
Impacts on the General Public. Both positive and negative
impacts may result from implementation of the proposed plan
relevant to the general public. Positive impacts can be
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expected due to increased farm and rangeland values in erosion-
prone areas, creation of new jobs, decreased cost of sediment
clean-up, increased useful life of dams, decreased incidence
of flood damage, and enhanced quality of aquatic resources.
Negative impacts may result due to the increased cost
and size of government, decreased tax revenues, probable
increase in food prices, probable decrease in funds available
for other programs, and possible inflationary impacts.
Future Planning Needs
The following aspects of the agricultural nonpoint source
problem need to be addressed in greater detail in the ongoing
planning program:
1. Mora emphasis should be placed on controlling the
emission of nutrients, salts, and pesticide from
agricultural lands into surface and groundwater
bodies.
2. Improved irrigation water use practices should
be emphasized as a means of reducing nonpoint
source pollution and conserving resources.
3. Results of the ongoing groundwater investigations
should be used to devise appropriate BHPs for
controlling groundwater pollution in severely
affected areas.
4. Provisions should be made for enabling the funding
of BMPs for improving soil erosion control on new
land brought into production under Desert Entry
and Carey Act procedures.
References
Idaho Soil Conservation Commission, Idaho Agricultural Pollution
Abatement Plan, 1979. *
19
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Section II - Livestock Grazing
History of Ranqeland Usage in Idaho
The livestock industry in Idaho began during the 1860s
as a result of increased mining activity. During that period,
herds of cattle were brought into the state to forage on
the abundant grassland and forest land resources.
At the time, no laws or agencies governed grazing use,
so water was the only factor limiting animal use. Sheep
were introduced and competed with cattle on the same ranges.
All grazing systems were dependent upon year-long grazing
which put persistent pressure on the forage resource.
The Taylor Grazing Act of 1934 enabled management of
grazing lands, although the interspersed location of public
domain made management difficult.
In 1939, Idaho passed the Soil Conservation Act, which
provided for federal assistance in the management of range
and pasture lands. "By 1976, approximately 950 ranch or
livestock farms had developed conservation plans in cooperation
with their Soil Conservation District and with the assistance
of the Soil Conservation Service" (Soil Conservation Committee,
1979). Also during the 1960s, coordination efforts among
the Soil Conservation Service, Soil Conservation Committee,
Bureau of Land Management and U. S. Forest Service began.
In 1968-1969, the Range Division of Idaho's State Depart-
ment of Lands was authorized to plan and manage grazing on
state lands. This program is still being developed.
Existing Ranqeland - Extent and Distribution
Almost thrae quarters of the State of Idaho is moun-
tainous, with the western portion of the state extending
into the Columbia Plateau. Within the mountainous areas
lie valleys and plains which can accommodate grazing. This
variety of terrain, which includes 12,000 feet of topographic
relief, generally supports 11 vegetation types. All of these
types, except the alpine zone, support livestock grazing,
as well as an abundance of wildlife, to varying degrees
(Daubenmire, 1952).
20
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Generally, spring and fall grazing occur at lower
elevations within the sagebrush-grass type, which covers
nearly 20 million acres of rangeland. Summer grazing occurs
in the undersrorv of open forests and parks, and in cutover
and burned areas of higher elevation forests (Pechanec and
Stewart, 1949) .
Approximately 21,283,344 acres of land in Idaho (65 percent
of the total land area of the state) are grazed, making livestock
grazing the most extensive land use activity in the state
(Soil Conservation Committee, 1979; Sharp and Sanders, 1978).
The number of beef cattle in Idaho has increased from 414,000
in 1940 to 1.8 million in 1975, while sheep production has
declined significantly from 1.8 million in 1940 to 560,000
in 1975 (Sharp and Sanders, 1978) (see Figure 2-3). An increase
in domestic horse use has been noted. There are an estimated
80,000 game animals and over 1,100 wild horses in the state
(Soil Conservation Committee, 1979).
It has been estimated that between 1975 and 1980, 51,540
acres of range and woodland would become urban lands and
243,070 acres would be converted to irrigated agriculture
(IDTID, 1977). Lands that are under application for Desert
Entry and Carey Act development may disrupt the economics
of several ranching operations.
Ownership and Management
Federal Lands
There are 52,913,000 acres of land m Idaho, of which
about 33,741,000 acres are in federal ownership. The U. S.
Forest Service has jurisdiction over 20,375,000 acres and
the Bureau of Land Management over 11,985,000 acres (Sharp
and Sanders, 1978). The Bureau of Indian Affairs lands will
not be discussed in this report. Of this federal acreage,
95 percent of Bureau of Land Management lands and 58 percent
of U. S. Forest Service lands are grazed, for a total of
approximately 23,203,250 acres.
State Lands
Livestock graze 84 percent of state-owned land, which
covers a total of 2,621,000 acres. The Range Division of
the Idaho Department of Lands sets policy and management
standards for grazing leases on state land.
21
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Private Lands
There are approximately 3,900 livestock grazing opera-
tions in Idaho using about 6,498,970 acres of private range
and 1,447,963 acres of pasture (Soil Conservation Committee,
1979). Only 31 percent of the land area of Idaho is privately
owned (Sharp and Sanders, 1978).
Ranch operations are very dependent upcn the lease of
federal and/or state lands for seasonal use, especially in
some areas of Butte, Custer, Lemhi, Minidoka and Owyhee Counties
(Soil Conservation Committee, 1979).
Description of Idaho Grazing Systems
There are basically three grazing systems that are used
in Idaho on federal, state, and private lands:
1. Continuous: "unrestricted livestock grazing through
the whole of grazing season" (Heady, 1975).
2. Rest-rotation: system by which pastures are alter-
nately grazed and rested. One pasture is completely
deferred for a full year.
3. Deferred Rotation Grazing: a system of rotation
grazing that incorporates one or more pastures in
deferment for a growing season each year.
All grazing management systems are aimed toward sustained
maximum utilization of forage by livestock and wildlife without
adversely effecting the range resource.
Nonpoint Source Pollutants
Erosion and Sediment
The most significant water pollutant from rangelands
is sediment, resulting from land erosion. This sediment
yield is an important concern because of factors including
"1) detrimental deposition on land and crops, 2) reduction
of reservoir storage capacities, 3) aggradation of river
channels causing increased flood hazards, 4) plugging of
canals, ditches and drains, and 5) increased evapotrans-
pirational losses by vegetation invading widening "floodplains"
(Branson, et al., 1972).
23
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Herbicides and Chemicals
Herbicides have been used in range improvement programs
for about 27 years, primarily for controlling brush regrowth
and noxious weeds. Picloram, 2,4-D and 2,4,5-T are among
the most commonly used.
As a result of these findings and other research, the
EPA has suspended use of 2,4,5-T on forest lands, rights-
of-way, and pastures which comprise about 79 percent of the
estimated 9.3 million pounds of 2,4,5-T used annually in
the United States (EPA, 1979). Use of 2,4,5-T for weed or
brush control on rangelands, however, has not been suspended.
Few studies have been directed toward the effects of
herbicides on water quality in Idaho. Preliminary data from
the Reynolds Creek watershed studies indicate that neither
herbicides nor insecticides have any significant influence
on water quality provided the material is not applied directly
on or within close proximity to a stream (Soil Conservation
Committee, 1979) .
Bacterial Contaminants
Several studies have been conducted on the influence
of cattle grazing on bacterial contamination of waterways.
These studies offer some insight into the mechanisms of this
kind of pollution. None, however, conclude that livestock
grazing is a significant health hazard.
Special Studies
Special investigations of nonpomt source pollutants
in relation to livestock grazing practices are being carried
out in the Reynolds Creek watershed in southeastern Idaho.
Preliminary results indicate that sediment is the major
pollutant resulting from 1) soil compaction in concentration
areas, 2) caving of streambanks, 3) trampling and/or consumption
of riparian vegetation and 4) overgrazing. Bacterial pathogens
are also significant nonpoint source pollutants where live-
stock concentrate around water sources resulting m introduction
of fecal material into the water.
Stream Corridor
Streambank erosion and destruction of riparian vegetation
are the most serious effects that grazing animals have on
24
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the quality of water. Livestock have a tendency to congregate
along streams for access to more succulent vegetation, for
available water, and for shade especially in semiarid areas.
This section will briefly summarize the combined effects
of allowing cattle to graze adjacent to natural waterways.
Riparian vegetation is very important to the integrity
of waterways, as it protects streambanks by reducing erosion,
helps deposits to build bank sides, and helps keep banks
from being damaged by ice, logging debris or animal trampling
(Platts, 1979). Along with undercut banks and streamside
debris, it provides cover for fish, moderates water tempera-
tures and controls water velocities.
Besides direct consumption by grazing animals, riparian
vegetation is influenced by trampling and erosion factors.
Physical damage to streambanks causes sloughing, channel
straightening, widening, a decrease in water depth, and
sedimentation (Armour, 1978).
Vegetation Changes
The concept of "deteriorated range" implies several
physical features of the landscape that have reacted to an
external influence. In the case of livestock grazing, a
concentration of animals causing severe trampling, heavy
early spring grazing, and general overuse of the forage will
cause a regression of the climax plant communities. As the
community deteriorates, deep-rooted perennials are replaced
by shallow-rooted annuals and biennials. If the condition
continues to decline, more soil becomes exposed and erosion
accelerates.
Wildlife and Aquatic Life
There is some degree of direct competition for forage
between cattle and several wildlife species. In Idaho, other
large herbivores sharing rangelands may include elk, antelope,
bighorn sheep, deer and wild horses. Often, management
practices do not consider these animals in calculating the
carrying capacity of a range. Studies by Hubbard and Hansen
(1976), Hansen (1976) and Olsen and Hansen (1977) indicate
that competition for forage between cattle and wild horses
is high; competition among cattle, bighorn sheep and elk
is moderate, and between cattle and deer is low.
25
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Soils
There are two significant impacts that grazing animals
can have on soils: compaction and "puddling" (Spedding,
1971). Compaction is defined as the packing together of
soil particles exerted at the soil surface, which result
m an increase of specific gravity by decreasing pore space
(Lull, 1959). Puddling is caused by the action of animal
hooves cutting into the soil when wet and leaving compacted
indentations (Spedding, 1971) .
Water Quality Problem Areas
Potential livestock grazing problem areas in the State
of Idaho have been identified as well as those areas under
good management programs. Potential problem areas, as
identified by the Soil Conservation Committee, mainly occur
adjacent to drainages of the Clearwater, Payette, Boise,
Snake and Bear River watersheds.
The Soil Conservation Committee has identified areas
having "priority" for range improvement. They are located
in the Weiser River Watershed of Adams, Washington and Payette
Counties, and should include the Big Willow Creek and Little
Willow Creek Watersheds in Payette County (Soil Conservation
Committee, 1979). The major portion of this rangeland is
characterized by shallow soils of the Sweet, Gwin and Melhorn
series and the precipitation zone is 10-16 inches. Runoff
is high.
Nonooint Source Water Quality Control
Planning in Idaho
The primary objective of the Agricultural Pollution
Abatement Plan, as it relates to livestock grazing, is to
recommend grazing practices and improvements that will
significantly upgrade the quality of runoff water from range-
lands. The IDHW-Division of Environment has been given the
responsibility of planning, implementing and regulating the
statewide 208 program for Idaho. The department contracted
with the Idaho State Soil Conservation Committee to prepare
the agricultural phases (including livestock grazing) of
the nonpoint source pollution control program (Soil Con-
servation Committee, 1979). "Due to funding and manpower
limitations, the IDHW's opportunities to expand its involve-
ment in nonpoint source pollution programs may best be
26
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accomplished by helping to implement the existing programs
of other agencies" (Montgomery, 1976). IDHW is presently
conducting water quality surveys in cooperation with other
agencies including Soil Conservation Service and the U. S.
Geological Survey- IDHW is also planning to engage in
cooperative programs with the U. S. Forest Services and the
Bureau of Land Management.
The Soil Conservation Districts, a joint effort of
the Soil Conservation Service and the Soil Conservation
Committee, have been working with land and water problems
for about 40 years. Because of their expertise and close
relationship with the private lands of Idaho, they have been
given the responsiblity of implementing programs for pollution
abatement by voluntary measures under the 20 8 plan. If a
regulatory program becomes necessary, Soil Conservation
Districts may become involved (Soil Conservation Committee,
1979) .
Cor.ceot of RMSs and BMPs
It would be impossible to prescribe any one solution
for controlling nonpoint source water quality problems on
grazing lands in Idaho. Therefore, the problems of the state
were assessed as a whole, and several solutions were identified,
any combination of which could be used on a local level.
The livestock grazing segment of Idaho's Agricultural
Pollution Abatement Plan relies heavily upon implementation
of designated RMSs and BMPs. The Soil Conservation Committee
11979) has defined these concepts as follows:
Resource Manacement Svstem: A combination of conservation
practices identified by the primary use (of land, or water)
which, when installed will as a minimum protect the resource
base by meeting tolerable soil loss maintaining acceptable
water quality, and maintaining acceptable ecological and
management levels for sustained yields of forest, range and
wildlife resources. Resource management systems, in addition,
should include conservation practices which provide for quality
in the environment and quality of life.
Best Management Practice: The term best management practice
(BMP) means a practice, or combination of practices, that
is determined by the State (or designated areawide planning
agency) after problem assessment, examination of alternative
practices, and appropriate public participation to be the
27
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most effective, practicable (including technological, economic
and institutional considerations) means of preventing or
reducing the amount of pollution generated by nonpoint sources
to a level compatible with water quality goals.
RMSs are basically being designed to accommodate three
types of grazing areas in the State of Idaho:
Rangeland
Grazable woodland
Native meadowlands
The concept of site-specific application of BMPs implies
that for the entire State of Idaho there could be any number
of BMPs if all the above variables are considered. More
often, however, generally accepted practices and application
procedures are adopted, thereby allowing experienced and
responsible persons to prescribe the BMPs for a particular
activity and site.
Table 2-2 contains 21 EMPs that are available for use. The
state water quality management plan calls for BMP updating
on a 5-year schedule (Soil Conservation Committee, 1979).
Several volunt^r" incentive orograns based or. cost sharir.g
have been identified and will be made available by the state
to ranchers.
Figure 2-4 illustrates the organizational structure
for implementation of the Idaho water quality management
plan for livestock grazing.
Impacts of Proposed 208 Plan - Range Element
The general impacts of livestock grazing on vegetation,
wildlife, fisheries and soil are discussed in the EIS on
the Range Management Program, Challis Planning Unit (Bureau
of Land Management, 1978). However, it can be surmised that
the impact of implementing a plan for improving range condition
and upgrading water quality will mostly benefit these natural
resources.
Vegetation
Access roads, stock trails and firebreaks will directly
disrupt vegetation in the areas of impact. Removal of brush
23
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Table 2-2
CATALOG OF BEST MANAGEMENT PRACTICES RECOMMENDED
IN THE AGRICULTURAL POLLUTION ABATEMENT PLAN
Practice* Type of Practice
-------
WATER QUALITY MANAGEMENT PI.AN -
Figure 2-4
IMPLEMENTING AGENCIES
AND THEIR RESPONSIBILITIES
U. S. EPA:
scc/scs.
1. Piovide technical-advisory
assistance for BMP and
grazing systems lmple-
muiiLu t ion
1.
Guide state in implementation
of 20B plan.
IDHW:
Coordinate implementation of plan
Develop water quality criteria and
monitoring program
Prepare annual status report on
208 plan
Water quality monitoring
I PL:
1. Encourge compliance, use of BMPs on
state and private lands
2. Assist in developing water quality
criteria and monitoring program
3. Evaluate and update internal programs
USGS:
1. Water quality
mom tor ing
BLM and USFS:
Apply BMPs on federal lands
Assist in developing water quality
criteria and monitoring program
Evaluate and upgrade programs
Coordinate grazing programs through
local SCDs for leases on mixed
ownership
fjiijlA .
1. Provide loans
to landowners
2. Eva]udte BMP
of fectivoness
SCDs;
1. Act as coordinator
for all grazing
systems involving
mixed ownership
2. Implement incentive
programs for range
improvements
3. Lvaluate BMP
e f fecliveness
ASCS .
1.
Provide technical
assistance and
cost-sharing for
approved range
conservation
practices
2.
Evaluate BMP
effectiveness
University of Idaho
1. Provide technical
assistance to
landowners
2. Conduct research
3. Evaluate BMP
ef fectiveness
ARS :
2.
Continue to
collect land
systems infor-
mation
Assist in col-
lecting stream
quality data
-------
can change the vegetation species composition to grasses
and forbs, which favor livestock and some wildlife. The
impacts to any rare or endangered plants must be determined
on a local level. While grazing management or livestock
exclusion may favor some species, others may be destroyed
from roads, developments or rotational grazing systems where
there is a short-term intensive use.
Soils
The protective cover of vegetation is expected to improve.
Erosion and sediment yields will be reduced.
Wildlife
It is assumed that any grazing management system that
includes BMPs will generally take into account wildlife use
of the range. However, as vegetation undergoes changes, wildlife
species dependent upon the community will either adapt or
be replaced.
Water Developments. Increased water development on
a range generally benefits wildlife. The distribution of
large mammals may be increased, populations and diversity
of species may be increased, and general stress may be reduced
(3ureau of Land Management, 1978).
Brush Management. The removal of brush may be detrimental
to small mammals, reptiles, and birds with limited home ranges
(Bureau of Land Management, 1978). However, it is beneficial
to all grazing animals and for browsers if the brush is decadent.
Fencing. While fencing may be important for protecting
streams and meadows and for grazing systems, it can be very
detrimental to big game. Large animals are particularly
impacted if the fencing is in the path of their migration,
if animals become too concentrated, and during deep snows.
Livestock Exclusion. Besides the increased available
forage for wildlife and protection of sensitive habitats, live-
stock exclusion can benent ground-nesting birds such as
sage grouse and blue grouse, which inhabit riparian areas
and wet meadows. Conversely, some livestock grazing can
be beneficial by retarding development of dense stands of
old growth vegetation.
31
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Aquatic Organisms. Aquatic organisms will benefit from
any BMP which reduces sedimentation and streambank erosion.
Impacts on Grazing Operators and Operations
It has been estimated that approximately $700,000,000
would be required to implement designated BMPs on private
range lands occurring in 40 Soil Conservation Districts
(excluding Ada, Canyon, Bingham, Caribou, Bannock, Power,
Oneida, Franklin and Bear Lake Counties) over a 20-year period
(Soil Conservation Committee, 1979).
Some estimates have been compiled of the costs for
supplying specific BMPs in Idaho (Nielson, pers. comm.):
Range Seeding $37/acre
Fencing $l,911/mile
Brush control $7/acre
Livestock exclusion $28/acre
Livestock water development $707/development
Range land mechanical treatment $34/acre
General BMPs, such as "proper grazing", cannot be assessed
in terms of costs.
Financial gains to grazing operations from implementing
range improvements will be minimal if at all in immediate
return although most will show definite long-term benefits.
Projects such as seeding and brush removal would produce
the fastest results.
Some of the long-term benefits to an individual operator
of using range improvements may include (Vallentme, 1971) :
1. Increased forage quantity
2. Increased forage quality
3.. Increased animal production
4. Facilitate handling of and caring for range animals
5. Control poisoning of livestock by poisonous plants
6. Reduce fire hazard
7. Increase water yields on watershed by replacing
woody species with herbaceous plants
8. Control erosion by stabilizing soil
9. Reduce conflicts between multiple uses of range
resources
32
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Impacts on Government Operations
The Soil Conservation Commission (1979) has given some
estimates of costs to government agencies and personnel require-
ments for implementing the Agricultural Pollution Abatement
Plan. Both the U. S. Forest Service and the Bureau of Land
Management have figured that their budgets would need to
be increased by $2,000,000 annually per agency for the entire
state. No estimates for increased personnel have been made.
The Soil Conservation District, as administrators of
the plan, would require about $100,000 annually per district,
or a total of $3,850,000 for the state (excluding Ada, Canyon,
Bear Lake, Bingham, Oneida, Power, Bannock, Caribou and
Franklin Counties) to implement the livestock grazing element.
Personnel estimates were given to enact the entire Agri-
cultural Pollution Abatement Plan, but technical support
for livestock grazing was not delineated.
References
Armour, Carl L. 1978. Effects of deteriorated range streams
on trout. U. S. Bureau of Land Management, Idaho State
Office.
Branson, F., G. Gifford and J. Owen. 1972. Rangeland
hydrology. Soc. for Range Manage., Range Sci. Ser.
no. 1.
Daubenmire, Rexford F. 1952. Plant geography of Idaho.
In: Davis, R. J. Flora of Idaho. Wm. C. Brown Co.,
Iowa.
Hansen. R. M. 1976. Foods of free-roaming horses in southern
New Mexico. J. Range Manage. 29:347.
Heady, Harold F. 1975. Rangeland management. McGraw-Hill
Book Co.
Hubbard, R. E., and R. M. Hansen. 1976. Diets of wild
horses, cattle and mule deer in the Piceance Basin,
Colorado. J. Range Manage. 29: 389-392.
Idaho. Executive Office of the Governor and Division of
Tourism & Industrial Development. 1977. Idaho almanac,
1977.
33
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Idaho. Soil Conservation Commission. 1979. Idaho agri-
cultural pollution abatement plan.
Lull, H. W. 1959. Soil compaction on forest and rangelands.
U. S. Dept. Agric. Misc. Publ. 7 68.
1976. Survey of nonpoint source pollution
programs. Prepared for Idaho Dept. of Health & Welfare.
Olsen, F. W. , and R. M. Hansen. 1977. Food relations of
free-roaming wild horses to livestock and big game,
Red Desert, Wyoming. J. Range Manage. 30:17-20.
Pechanec, Joseph F. , and George Stewart. 1949. Grazing
Spring-Fall sheep ranges of southern Idaho. U. S.
Dept. Agric. Circ, 308.
1979. Livestock gra2ing effects on fish and
riparian environments (a compendium) - draft. Intermoun-
taxn for. Range Exp. Stn., U. S. For. Serv., Boise,
Idaho.
Sharp, Lee A., and Kenneth D. Sanders. 1978. Rangeland
resources of Idaho. Idaho Rangeland Com. Misc. Pub. 6,
Univ. of Idaho.
Spedding. C. R. W. 1971. Grassland ecology. Claredon Press.
U. S. Bureau of Land Management, Idaho Stte Office. 1978.
Final EIS supplement. Proposed domestic livestock
grazing program for the Challis planning unit.
1979. 2,4,5-T and Silvex. Introduction to
suspensions and notices of intent to cancel. Fed.
Reg. 44(52): 15874-15917.
Vallentine, John F. 1974. Range development and improvements.
Brigham Young Univ. Press.
Personal Communications
Neilson, Glen L. April, 1979. 208 Consultant, Idaho Depart-
ment of Lands.
34
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Chapter 3
ERRATA
Paae xiii, Paragraph 3, is Changed to Read as Follows;
The upper Snake River and Southwest Idaho Basins are
the major crop producing areas of the state. Grains, potatoes,
sugar beets, hay, vegetables, and pasture are the predominant
crops raised in Idaho. About 14 percent of the Palouse River
Basin lies within Idaho, and this dry-farmed area produces
large quantities of grain. Grazing land is distributed
throughout the state.
Page xiii, Paragraph 4, Line 7:
The value shown as 6.6 percent is changed to 66 percent.
Paae xv, Line 4 change Sentence to Read:
Highly erodible soils are found throughout the northern
panhandle area, the upper Snake River Basin, and in the Bear
River Basin.
Page xv, paragraph 3, line 3, change southeastern to
southwestern.
Page 1-1, paragraph 1, line 10, change 1,000 to 1,100.
Section II - page 1-4, change the vegetation zone shown
as 0£>k-mountain mahogany to mountain brush.
Page 1-4, alpine zone, change 19,000 feet to 9,000 feet.
Page 1-7, paragraph 4, line 2, the words "grazing rights"
should read "grazing privileges".
Page 1-7, paragraph 2, last line, change five to six.
Page 1-7, paragraph 6, line 2, change Idaho Soil Con-
servation Service to Idaho Soil Conservation Commission.
Page 1-8, paragraph 6, delete second sentence - However,
any system...
35
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Page 2-3, paragraph 3, delete the last sentence beginning —
a recent epidemiological study ...
Page 2-10, paragraph 1, line 7, insert words, "when wet"
into last sentence as follows . . . the soil when w^t and . . .
Paae 2-10, Paragraph 2, Lines 3-5, Change Second Sentence
m Paragraph to Read as Follows:
Maximum compaction occurs when the upper 4-6 inches
of soil surface is wet and plastic and when there are soils
that have a high porosity or high range of particle size
(Soil Conservation Service, A. I Garrison, Sr., 1979).
Page 2-10, paragraph 4, item 1, change wording to read
as follows: 1. avoid use of pastures when soils are saturated.
Page 3-2, paragraph 3, line 6, replace word enacting
wich implementing.
Page 3-2, paragraph 5, line 3, insert state before grazing,
i.e., ... on state grazing lands.
Page 3-5, paragraph 3, line 2, insert more in line 2
between for and technical, i.e., for more technical advisors...
Page 5-3, paragraph 6, item 5 in table should read
707.00/development.
36
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Chapter 4
COMMENTS ON THE DRAFT EA AND EPA RESPONS
37
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,/Sn Uniicd SUtai Soil
OtpirtmiH Ol ComcniUOA
A|nc«llKU SannCt
Boon 34 S
304 .occh 8th Scraac
ftolss, Idaho 83702
Saptaabar 21. 1979
RECEIVED
Craig Parcrldga H/S U)
EnvlronaaoCal Evaluation Branch ££P 2? 1979
Eovlronmancal Proeocdoa Agancy. Raglon 10
1200 Slacb Avanoa r~ - -
Saaccla, Uaahlngcoa 96101
Oair Mr. Parcridga.
Ua hava uvUucd (tii CnvlrooMatil AmiiMOt (or cha Agricultural
Craalag ItutUi* «1«moc of lh« U«ho Scacawida 'J«ur Quality
mo( Plan aod hivi cha followlog coaoaota.
1 Swanarr - PJ 1 Saccloo I, Chaptar 2 - You hava iodlcacad that nucnaoc and paat-
lclda pollution occurs la ralaclonahip with tadlauc Ua (aal
you ahould giva thla *ora aapnaala lo this cbapcar. Nuattoua
taaaarch projacca hava ahowo that ooat oucrlanca aod paaclclda
pollution occura only whan tha aoll partlclaa thay ara attachad
to aro oovad by aoll aroaloa procassas. Ua (aal that you ahould
aapbaalsa that politician of chaaa aUaaoti la primarily aaaoclacad
wlcb aoll aroaloo ao wa cao propaxly oucllaa cha solucloas. Stopping
•rsiloo la tba bast way Co atop pollutloa of ssdlaancs. outrlaota
aod pasclcldaa.
) | Sactloa 11, fa|a 1*4, aacood paragiapb - Tou Indicaca chara la
^ I about ona half tail 1 loo acras of oal aouncaln aaho|«ay lo touchtn
I Idaho Ua luuw of ao oak growtag lo Idaho Thaca la a eonaldar-
I abla aaounc of aouncaia bahogaoy. howavar, wa would quabtloo (hat
thara would ba a half aillion actas. lo Cha alncb paragraph, paga
^ I 1"^. you lodlcaca chac cha Alplna iona la loutharo Idaho Is abova
I 19,000 laac. This Is Incorrect as cha hlghaac aountain paak In
I Idaho Is soaachlng a lltcla ovar 12,000 faac Ua aaka a »u|sascion
that you uaa Land Rasourcas at Idaho as a rsfaranca for pocancial
Ivagacatioo. Thia docuoanc la availabla (rta Cha Idaho Rangaland
Coaaittaa, Mlacailanaoua fuklicilioo *ant with cha laat aantanca
of chla paragraph, buc wa quaaclon othar parts of cha paragraph
Tha rafaranca you clta la aoaa 26 yaars old and chara haa baan
cnoaldarabla raaaarch dona ibac altara soaa of cha scataaaats you
aaka Id chla paragraph.
9. Paga 2-1. paragraph 3 - Tba laac scotaaca of cha paragraph is highly
co&cravarslal and wa suggasc chac you ahow a rsfaranca Indlcaclng
whara Cbls scalaaanc cans Cro«.
9. Paga 2-9. Tabla 2-1 - Mora currant daca for chla cypa of cabla la
availabla fro* Cha SCS tUclooal Raoga Handbook and wa amggaac you
uaa Chla rafaraaca for cha nuabar of aoloala par aniaal unit.
10 * Paga 2-10. paragraph 1. laac aancanca - Suggasc you lnsarc 'whan
a I wac' afcar Cha word 'soil1 Tha aancanca will than rasd. "Puddling
| Is csuaad by cha accloa of anloal hoovas cutclng Into cha soil whan
* wac " (Spaddiog 1971)
b I Paragraph 2. aacood aancanca - Ua auggaat chat tha aantanca raad
I aa followa. "Haxioua co«paccloe occurs whan tha uppar tour Co aix
I lochaa of aoll aurfaca la wat and plaatle and whan thara ara soils
I that bava a high poroalty or high ranga of pacclcla sl
-------
Crals "artrldje
09/11/79 P*gt )
11 P«ge 3-2, Under the boadioi tbjor State Protranu. pilijrjpb 1,
••nceoce 3 - Use the word loplaaene lnicud of enacting Pin-
graph ), flrtt itac«ae« - lotirt the word 'stece* prior to
}(4tlD| liadi
12 Page 1-5, chtrd paragraph - u« aug^est you insert the word 'aore*
bifori cectmlcal advisors
13 Pag* 3-3, adder the subheading Imoacca oo Grating Operators ind
Operttiom - Ve question the ease estlauca oa wi«r developoent
Should (hit noc reed, " $707 00 par devalopaenc.** rather
than acre
14 Pag* 3-2, Table 3-1, under the ftflf't. deferred grating should also
show beosflts Cor wildlife and aesthetics Planned grating svste^s
will also eohance aeschetlca end will be a wildfire hatard reduction
Proper gracing use will iaprove wildlife habltac, aesthetics and
prevent •creambank aroaloo Tha 6flP. proper pesticide application,
utll also lsprove wildlife habitat and finally. proper woodland
gracing should show iapravcMnt co wildlife and atatheclca
Ue chaok you Cor Che opportunity co review end cocnenc oa thla anvironsentel
aaieaiMQt
-------
U 3 Qjoartment of Agriculture, Soil Conservation Service,
Poise,'Idaho, K Garrison, 3r , (September 31, 1979)
I Change udo through Chapter 3 - ERRATA.
2 Tha movement of phosphorous and pesticides Is certainly
associated with tho erosion of soil particles, and wo
feel that tha report adequately brings this fact to
tho attention of the reader It would be unjustified,
however, to suqgest that a solution to the state's erosion
pcoolem would necessarily bring about a cessation to
all ocher nonpolnt source problems More specifically,
the emission of voluble salts and nitrates would con-
tinue to occur even with complete control of sediment
loss The escapa of these pollutants is primarily a
function of water and fertilizer use practices.
3 a Oak-mountain mahogany is an error This vegetation
zone is mountain brush. The change is made via
Chapter 3 - ERRATA
b. Tha elevation should be from sbove 9,000 faee in
southern Idaho to above 7,000 faet in northern
Idaho.
c This reference was used.
4 The consent wea aoted and considered. For the purposea
of this £A, roevaluatlon la deemed unwarranted becauae
a change in the data shown *ould not significantly
affect approval of the water quality management plan
or raiae new adverse lasuea.
5 Our notes indicate that the deta was compiled by the
Idaho Soil Conservation Coennlaaion not the Soil Con-
servation Service. The reference is shown on page 6-2
as Idaho Soil Conservation Commission. 1979 Idaho
Agricultural Pollution Abatement Plan
6 This sentence la delated via Chapter J - ERRATA.
7 Comment noted and no response required
0 It is agreed that the statoment is controversial, and
a reference substantiating the statement is not available
at this time Thus, tho sentence is deleted via Chapter 3 -
ERRATA.
9. Comment noted, no roeponse required.
10 a. The worde, when wot. Inserted via Chapter 3 - ERRATA
b. The suggested change in wording made via Chapter 3 -
ERRATA.
c. Tha suggestod chenge in wording made via Chapter 3 -
ERRATA
11. Changes made via Chapter 3 - ERRATA.
12. Change made via Chapter 3 - ERRATA.
13. Zt should read 707.00 per development
14. Consents noted. No reaponae la made because these changes
are Judgmental and would not significantly create raw
issues or dAta for the water quality managoDent plan
-------
UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SUflvEY
WATER RESOURCES DIVISION
box 036 Federal Building, Koea 365
330 Ueat Tart Street
Boli«, Idaho 8)724
Septnber 25, 1979
RECEIVED
SEP 2 7 1979
Craig Partridge cr*.c~
Envlronaencal Evaluatloo Branch
Covironaantal Protection Agency, Region 10
1200 Sixth Averuia
StitcU, UA 98101
Dear 1r Partridge*
After reading the Eavlronaantal Aaaeasaeac Idaho Agricultural and erasing
Practlcee pare of cha Idaho Statewide Uater Quality Haoagaaeot Plan, wa
hava (ha following consents to sake
1 [ Page *111, 3rd paragraph - Shouldn't tha Palouaa Country la oorch
I Idiae ba Included aa a ai)ec crop produclog area?
2 i P*t* *ltl. 4th paragraph - about 6.6 percent imi la atror, ihmld
| chta ba 66 percent?
J 1 P*t« rv, 4th Una - highly arodlbla dry land faming araaa alao occur
I In cha upper Snaka llvar baelo
4 I Paga 1-16, 2nd paragraph, lac eencaoce - lb a taodlf lcaclon of atreaaflow
I begiaa ac Aaderaoo Ranch *ad Arrovrock Jieaarvolr.
3 Page 2-16, 2nd paragraph, 3rd sentence - This aancanca la not clearly
stated, it ahould convey chac undar ragulacad conditions "high** flow*
now occur during lata lunar and aarly (all, whlcb uodtr natural con-
ditions waa a parlod o( low flows
^ | Page 2-16, 2nd paragraph, 7th aantenc* - Encroachaent by ouin and
I deposition of aedlnant (to* lrrlgedon draina hava alao coatrlbuced to
I decreased capacity
j Page 2-16, lat pacagraph, 3rd aancanca - and in all certainty levels
vara be Low tha rivar boccoa " ahould read and possibly below cha
civar on ita touch ilda " It la not cartaio that ground water In
the north aide Coechllla did not dlecnarga into tha river
9 l Pi^«i 2-fl to 1-14 * The discussion on nonpolot aourca pollucion doaa noc
I oentlon pollution froa fish faralng operations ia tha Ulnar to BuhJ
I and downatteaa reechet. or are thaaa considered aa point sourcea?
Ua hopa tha above coaaaoca will ba oC aoma help to you
Sincerely yours,
**lph T rarvicch
Accing Olacrlcc Cblef
-------
U 3 Ocoarspent of Interior, Geological Survav. Bolaa.
Idjno, R F Worvitch [September 25, 1979^
1 Chang# made via Chapter 3 - ERAATA.
2 Change made via Chapter J - ERRATA.
3. Chan?* made via Chapter 3 - ERRATA
4 The raach of the river where water quality la algnifi-
cancly influenced by a combination of agricultural
return water and streamflow regulation is downstream
of LucKy Peak Reservoir Certainly Anderson Ranch and
Arrowrock Reservoirs alao affect inatreao flow.
5 Comment noted, and no response is made
6 Pago 2-16, 2nd paragraph, 7th sentence - aadiaent (roa
irrigation return flows has certainly contributed to
the decrease in channel capacity We feel that the
caae study gave due attention to this point. In addi-
tion. reduced flowa in the main channel increaae both
tha rate and total amount of this sediaont which remains
within the Boise River environment. The sentence could
be modified to readi "reduced flows in tha Boise River,
in addition to other factors such a» sedlmnt contributed
from irrigation return flows and urban encroachment,
have resulted in a decreased capacity .
7. Page 2-18, lat paragraph, 3rd aentence - the sentence
should readi *... and in all certainty levels were
below the rivei bottom on the aoutb aide*
9. The particular effects of wastewater from fish farms
and hatcheries were not considered in this report.
Copending on individual circumstances such operations
may be either point or nonpoint sources The nonpoint
source pollution problems associated with trout hatchents
in tha Uageroen Valley .area are discussed in a separate
element of the 208 effort
-------
United States Department of the Interior <«o>
bureau or uno management nECEIVcD
Idaho State Optica cro _
ftdaril Bulidlo|( Box 042 "*» ' 19'3
550 «*. Fort Street
Boise, ID 8J724 -P^.c
S«pc«nb«r 23, 1979
ir Craig Partridge ft/S
EnvlroraencaL Evaluation Branch
EnvironaencaL Procecdon Agency, Ragioo X
1200 Sixth Avenue
SaaccU. UA 98101
Dear Mr Parcrldg«
Thank you (or tha opportunity Co ravUv and comat on the draft envlron-
aencal staceaenc dor Idaho Agriculture and Crazing Practices
Ua offer the following generel and specific consents on Cbe livestock
Crating In Idaho aecclon.
Canaral Cocnents
U« believe the iiiaancnc adequately cowra the proposed Uacer Quality Flin
but My not praitot a claar underecendlng of gracing induced iapacte to
thoaa uofaalllar vlch ceogelend aioa|«aai)c Ua would like to aaa a sore
thorough coverege of tha Ilvaetock induced iapacts aa they cospere to
othar practlcaa and tha existing aovironoent Ua raallxa that quentlflca*
(lon la lacking on chit subject and It would ba a good Ida* co point this
out Id tha docuisaat
Specif Ic *Co8nents
P| 1-1. Introduction. Thara ara about 1.100 wild horaea La the Scaca aa
of Sapteabar 1, 1979
?; 1-7. fiJtttl p«t«4taph 2 Th« uoidi "teasing tights" ihouU
read "grating privileges '
P< 1-7. Faderal Landi. paragraph 2 Tha Taylor Crating Act glvaa aucbor*
Jxacloo co is sua licenses or peraits co grata livestock oo public lands
Laaaaa only ara laauad for thoaa araaa oucalJa established grating district!
under Sactlon IS ol tha Act
t
P< I-?. F«daral Lands. pir<|r3ph_?
offices and a state o(fice
ccnsenvc
Tha Bill io Idaho ha a a 1* district
Sav* Entrfy and You Serve America/
6| Pc 2-2. Eroalon Sediment, paragraph 3 Tha discussion on natural and
1 introduced aroaioa should ba discussed io parspactlva with tha rast of
I tha State, 1 a., ara tha (actors listed **lo order of importance" applicable
I co othar araaa* 1a various aoil typaa, etcl
7 Pq 2-* Bacterlel Concaalnaota, paragraph 1. This paragraph scaCas that
no study concludes that livestock grating is a significant health Saiard
Page 2-6, Ho 6 states that probable effaces fro» livestock grating are
increases io pathogenic bacteria. Soaaching should be said about che
likelihood of health hacards where livestock usa occurs oaar public later
sources
Again, thank you for tha opportunity co review aod consent oa this docuaeoc
and if ua can of any aaaietaoca, plaaae do not besltace to ask
Sincerely yours.
cc.
U0 202-B
-------
U S Department of Interior,. Bureau of Land Management
Boiflo. rdaho, T G. Binqnaa (September 25. 1979)
L. Carmen t noted, end no response Is required
2 Change nude via Chapter J - EHRATA
3 Chjngo made via Chapter 3 - ERRATA
4 Commont noted; the word lease Is used as a vernacular
tern and as your comaent applies it is a special tera
The staeement then should probably read license, pernit
or lease
5 Chanqe aade via Chapter 3 - ERRATA
6 Coauaent notedt detailed discussion and revision of the
statements do not seen warranted for this report.
7 Increases in bacterial contaminants ss cooaonl/ monitored
by total colifora, fecal colifora and other tests are
associated with Livestock, because the laboratory tests
used do not distinguish between buuMO and livestock
origins. Baeed on indices of risk to public health,
elevated bacterial counts imply a greater risk to
hucoanai whether the risk is factual or potential ie
difficult to assess, thus Judgeoents ere usually stated
on the conservative or low risk side.
-------
United Slates Department of the Interior
FISH ANO (VII OLIFt SEKVICt
ECOLOGICAL SERVICES
4620 Ovarlaod Igid, Kooa 209
hecqvho u*ho 81,05
OCT 2D 1979 Oc.ot.r
^PA-Cj<5
Craig Partridge 1/3 44)
Cavlrona«ot«i Evaluation Branch
U S CnvlroftMatil Protection Ageocy
Begloa 10
1200 Sixth Aveaue
Seattle. Uaeblagtoa 98101
Dear Mr Partridgai
u« have revlevad the Cnvlronneocal Asaataeaat for the agricultural eod
grating practical eleoaot of tho Idaho Statavida Uater Quality Kaaage-
aaot flan traoialtted Sapteaber 21 Our cosaeeta concern choaa etreaaalda
landa tocatad douoatreaa fcoa Anderson taoeh Oaa to tba vicinity of
Dansklo Bridge (11 allaa) oo tha South fork Boiaa filver tha South Fork
Sola* Blver la claaslflad as a Claaa I atraaa (blgheat-velued ftaba 17
resource) atrtta aecordlag to the 1978 lcr«ta evaluation Hap - Stat* of
Idaho, aod It rank* aa oaa of tba top flatting strsaaa La the Stats
On tha tap, Araaa Uhera Erosion Froblacs Hay Exist Fro® Livestock Grating
[a tha State of Idaho, Tig 1-3, tha lands alongside tba South Fork ftolaa
tivar balov Anderson Bench Oaa have not been Identified as a ptoblea
«raa tvia though tba slopes of auaaroua tributaries to tba South Fork
Boise Blver ara Indicated aa areae effected by llveetock graxlng precticee.
Tha steep uppar alopaa and tributary atreaas ara being daaagad by llvaatock
graxlog, therefore, the aala atraaa la uodeigoiog alailar aod accumulative
daaego by these graxlog practicaa
Va understand that rest rotation grating la being practiced In (his
araav but alaca there era no containment Uncta, ibis process seeaa to
exist only on paper During our on-going fishery atudlaa oo tha elevao-
alia rivac aactlon fcoa tha to Oaoaklo Brldga, «a observed chat
taitU and sheep gracing practices ba*e, and ara coatloulng to sawaraly
affect tha riparian end aide hill habitat
k* suggest that this sectloo be shaded oo your nap or another field
Lcspectloo be conducted to evaluate tha graxlog affects la this area,
especially sloes tha adjacent hills and tributary valleys Uadiog to the
oako streaa ara already Qftted as problea acats.
T^ank vou for tha opportunity to consent 00 this aaseteoaot.
91ocarsly yours,
I'.LQZJl
Richard J
Field Supa
cc. Bagloa i, UFfcG
AttQI Ulll Bold
-------
U S Duoartmant of Interior. Fish and Wildlife Service,
Boise, tdaho, R J Fisher tOctober'^5,ISV^)
During cho compilation of materials for the 6A, field
observations ware not made Extent data and reports uera
roLud on Co Identify problem areas. Th® EPA appreciates
your conments which sre included herein. Because this in-
formation will not significantly alter the state's 200 water
quality management plan or raise new adverse environmental
issues* we do not propose to do the data review or revise
Figure 1-3. we do accept your opinion on the matter.
4>
On
-------
office or county commissioners
IIHXI COUMIT
Salmon iOaho
oo" « o «»**.
leuit qimo) * Chairman
Jataes Ellsworth
December 10# 197 9
Craig Partridge M/3 441
Environmental evaluation Branch
EPA Rogion 10
1200 Sixth Avenue
Seattle, Washington 98101
Dear Sir.
w« recently received ¦ copy of your publication - Environmental Asseasment-
rdaho Agriculture and Grating Practices.
Frankly, we art a little skeptical about your data on the Salmon Baain. On
page 2-41 you note that about 4% of tha atatawlde sediment ylold from agri-
culture is associated with the Salmon Basin.
Host of the agricultural land in the Salmon Baain is located in Custer and
Lemhi counties Privately owned farmland in the Salmon Basin in these two
counties amounts to about 273 thousand acres, or 1 9% of the state total of
14 3 million acres. Harvested cropland totals about S7 thousand acras. or
1.31 of the state total of 4.S million
The economy of this basin is a livestock economy. Over 94% of the harvested
cropland is seeded down to alfalfa or native meadow hay Me find it hard
to believe that this type of apiculture yielding very little surface run-
off on 1.3l of the acreage can contribute 41 of the sedifflent
We also question the statement about the "notable impact" of irrigation
diversion and return flows in the same paragraph. A four year study of
the Leohi River completed in 1973 by the Idaho Department of Health reveals
that the river is not significantly impacted by agriculture between Leadore
and Salmon. This is the area of most intensive agricultural development
in Lemhi County Although w« have seen no data on the Pahsimeroi River,
w© suspect that a study there would indicate the same thing
Thank you for inviting comments
Sincerely,
- -
Louie Oemick,
Chairman
Lemhi County Commissioners
"cCEfVED
21 1979
EP*.Cl«
LD.aw
Lurchi Countv, Otflco of County Commlaaioners. Salmon. Idaho
L Detruck (December 19. 19791 '
1. The data and information used in the assessment was
transferred from reports compiled by the state (IDHW)
Department of Ecology in their preparation of the 208
water quality management plan Without Intensive re-
evaluation of all data we have no means to respond to
your consent. Since this difference in the data does
not significantly alter the atate's water quality
management plan or create new Adverse environmental
issues* we note and consider your coognent, but plan
to take no further action on the matter This final
EA will be sent to the State 1DHW-006 for their review
2. The use of the word notable is a matter of judgment.
It does not necessarily mean that the rivers are sig-
nificantly degraded, only that measurable change, i e..
Impact, can be discerned from the monitoring data for
tho Lemhi River
-------
COOPERATIVE exteiision SERVICE
cjumbou. • vX' Unlvsrsityor Idaho
P O 80i A
Sanson id*no aHOf
*wn. (JM| 799 2024 U 1
(lovember 9, 1-979
RECEIVED
Craig Partridge U/S *i3
Zr.vironaental Evaluation Branch
EPA Peglon 10
1300 Sixth Avenue
Seattle, Washington 96101
Ooar Sir.
1 recently received a copy or your publication -
£r>'- tronnental Assessment Idaho Agriculture and Grating Practices.
1 I would like to taLe exception (o one paragraph on page
2-*l In the book. In the paragraph on the Saloon Baaln >ou note
that about of the statewide sediment yield from agriculture
orlgirates In the Salmon Basin. As Anyone familiar with ag-
riculture In the eaoln will tell you, that Is patently absurd
Although much of the sediment in the LerJii and Saloon Rivers la
a result of alterations of streaa channels, noat have nothing
to do with agriculture. In the Lemhi River, for example, most
of the chanrelisation occurred In 1910 when the railroad was
built from Leadore to Saloon. Some additional channelisation
was associated with the new highway In the early "50's*. Most
erosion on the Lemhi la stream bank erosion resulting from
hydrologlo forces oreated'by those channelization projects.
Although the erosion takes place on private ranchland, it has
nothing to do with agricultural practises.
You to on 64 state that lrrlsatlon diversions and return
2 flow are "felt to hav« s notable Impact on the Leanl and Pahsioerol
Rivers (Idaho Oept of Health and Welfare, 1976.) The lack of
analytical data on these streams males an assessment of agricultural
Impacts Infeasible.*
Hog'ash! The Pahslmerol River is one of the top trout
streens In Idaho and Is an Important part of the recsinlrg steel-
head fishery In spite of the fact that it Is 1005 appropriated
for Irrigation To my knoiledso. no studies have bean dona on
the Panslmerol (that much of your paiagraph Is true).
Ilow, the Lemhi la a little different matter It is not
only a top fishery for trout, steelhoad, and aaltron, but it
has also been studied to death Ly both the Idaho Fish and Came
Cepartrent and the Idaho Dopartrent of lioalth.
r:cv I 3 1979
f,a£t» 2.
">e fill
Icilrs da:a
1s froe a report
of the Ida;
-o icpar-ctn; of
-ealti.
Enjlieerln,
i and
Sanitation
Division, rcc&^sllo.
Idaho
t cn the L^ahl
Pj*er
0 0.
Hltrate
"nosphate
5-day BCD
Cite
- ~
- " - PF1 - "
"\uolditv
-rzj 1-
-
3-12-70
10.2
2.1
.09
0
3 5
S
8-12-70
9.3
2 6
28
0
5 0
L
1C-J5-70
11.0
1.3
00
0
1 1
S
10-25-70
13 1
.9
27
0
1.0
L
7-:j-7i
10.6
.7
os
3*
1 3
S
7-29-71
9.7
1.1
.09
4
2.1
L
11-11-71
10 2
.7
.01
a
2.2
S
11-11-71
12. Q
.7
.02
no
5 0
L
7-5-72
9.n
1 1
< 01
1
3.2
3
7-5-72
a 2
l 5
04
3
1 1
L
10-19-72
11.0
2.0
.02
17
3.0
S
10-19-72
11.3
.1
.08
23
2.1
L
7-2M3
U.2
2.2
< .01
17
1.7
3
7-21-73
10.2
2.3
.07
2
> e
L
10-11-73
u.a
2 6
.09
35
1.5
3
10-11-73
12 tl
i a
.27
30
1 8
The letter L stands for Leadore, a small burg at the head
of the Lemhi Vallay. There Is very little agricultural develop-
ment above Leadore. The lector S stands for Salmon, the county
seat which la at the mouth of the Lemhi River. There are about
60 river miles between the t«o sampling polnta.
During July and Auguat all the river Is used for lrrlcatlon
Ic la over 1005 allocated. Without continuing return flows it
would be dry. After October 1 over SO,000 hoad of cattle are
pasturod along the river.
I have subjected these data to statistical treatment and
can find no differences Tou can pull out one sacple and say,
atjy, look at the degradation," and then uhon you look at the next
-------
za~.pl:, :r a* tre ncana and standard '. iicJor Tor su-.-«r cr
""ait or sut.j.- and fall . ou find tua: t i1fferticcs J -1»; do
roc exiat
ton, Uo>s| I think you should to horeat. Rewrite that
paragrarh to raed
raIt.c* saslr
?ne Salmon 3aaln has little agrlc-il^-re and contributes
dn irrslsurasiy small percentage of the statewide aedicent
j laid Croi agriculture No streams ero coralderod to be r.oro
than a lightly affected by agriculture In this basin.
Sincerely, .
^ooert R Loucka
Lemhi Count/ Agent
c c Jin hdhklna
Ldtnnl County Coicmlsslon
5111 Safer, Lemhi SCO
Paul Allen, Lemhi ASC3
Uni orsicy of Idaho, Cooperative Extension Service. Salnon
Idaho. R ~ R' 'Loucka iNovember 9. 1979)
1 The data and information used in the assessment was
transferred from reports compiled by tha state (IDHW)
Department of Ecology in their preparation of tha 200
water quality management plan Without intensive re-
evaluation of all data we have no mans to respond to
your concent Since this difference in tho data does
not significantly alter the state's water quality
management plan or create new adverse environmental
issues, wo note and consider your comment, but plan
to take no further action on the matter. This final
EA will be sent to the State l0H«<-OO£ for their review
2 The use of the word notable is a matter of judgment.
It does not necessarily mean that the rivers are sig-
nificantly degraded, only that measurable change, i.e .
iapact, can be discerned from the monitoring data Cor
the Lemhi River.
It seems true that the analytical data on these streams
is Insufficient to make a quantitative assessment of
the agricultural impacts, per set however, the data
supplied with your letter indicate that the Lemhi Rivar
is enriched with nitrate and that the growth of algae
is probably limited by low concentrations of phosphorous.
3. Other comments ere noted, but oo response is required.
------- |